Understanding the EU Packaging and Packaging Waste Regulation (PPWR)

The EU Packaging and Packaging Waste Regulation (PPWR) represents a significant shift in packaging sustainability requirements across all Member States. Replacing the Packaging Directive (94/62/EC), it establishes stricter rules on recyclability, waste prevention, and reuse. As of the 4th of March 2025, this article reflects the latest available information on these regulatory changes.

For businesses that produce or use packaging, understanding these new obligations is crucial for compliance and maintaining market access in the EU.

This guide is divided into two key sections:

1. Obligations for Packaging Producers – detailing the specific requirements companies must follow.
2. Key Regulations and Guidance – providing an overview of the legislative framework, enforcement, and compliance steps.

Under the PPWR, packaging producers must adhere to stricter sustainability measures aimed at minimising environmental impact. These obligations include:

1. Ensure Packaging is Recyclable at Scale

• By 2030, all packaging must be designed for recycling according to defined criteria.
• By 2035, packaging must be both recyclable and effectively recycled at scale, meaning at least 55% of each packaging category is successfully recycled EU-wide.

2. Use Minimum Levels of Recycled Content in Plastic Packaging

Producers must incorporate minimum levels of post-consumer recycled (PCR) content in plastic packaging:

• 10% by 2030 for food-contact-sensitive plastics (25% by 2040).
• 35% by 2030 for all other plastic packaging (65% by 2040).
• 30% by 2030 for PET beverage bottles (65% by 2040).
• Applies to plastic components constituting 5% or more of total packaging weight.

3. Reduce Packaging Waste & Optimise Packaging Design

• Packaging weight and volume must be minimised while ensuring functionality.
• Ban on certain single-use plastic packaging types from 2030 (e.g., for very lightweight fresh produce, hotel toiletry bottles).
• E-commerce packaging must not exceed 40% empty space to prevent wasteful over-packaging.

4. Implement Reuse and Refill Solutions

• Certain industries (beverage, hospitality, e-commerce) must increase the share of reusable packaging.
• Develop and manage reuse and refill systems designed for packaging collection and reusability.

5. Comply with Harmonised Labelling Requirements

• Standardised labels on all packaging to indicate:
• Material composition for recyclability.
• Disposal instructions for consumers.
• QR codes or digital links must provide additional recycling information.
• Labels must be consistent across all EU countries.

6. Extended Producer Responsibility (EPR) & Eco-Modulated Fees

• Companies must finance and participate in national EPR schemes.
• EPR fees are eco-modulated, meaning:
• Easier-to-recycle packaging pays lower fees.
• Non-recyclable or hard-to-recycle packaging incurs higher fees.
• Producers must submit detailed data to demonstrate compliance.

7. Demonstrate Compliance Through Conformity Assessments

• From 2030, companies must prove compliance with design, recyclability, and waste prevention rules.
• Compliance documentation must be available for authorities upon request.

8. Eliminate Certain Hazardous Substances in Packaging

Packaging must be free from harmful substances, including per- and polyfluoroalkyl substances (PFAS) and other restricted chemicals.

1. Who Does the PPWR Apply To?

• Covers all packaging materials, not just plastics.
• Applies to all packaged goods sold in the EU, including imports.
• B2B and B2C packaging are both subject to the regulations.

2. What Are the Key Objectives of the PPWR?

• Reduce packaging waste by 15% per capita by 2040.
• Ensure all packaging is recyclable by 2030.
• Increase reuse and refill systems across key sectors.
• Introduce harmonised labelling to improve consumer recycling habits.

3. What are the Material-Specific Regulations?

• Glass, paper, metals, and plastics must meet specific recycling targets.
• Recyclability assessment methodology will be fully implemented by 2028.
• Recyclability must be assessed per packaging unit rather than by weight.

4. When Are the Compliance Deadlines under PPWR?

• Official Journal of the EU: Final PPWR Text
• Green Business: New EU regulation promotes the procurement of sustainable packaging – European Commission
• European Chemicals Agency: Understanding the Packaging and Packaging Waste Regulation – ECHA

The PPWR sets out a clear roadmap for sustainability in packaging, placing increased responsibility on producers to:

• Design packaging for recyclability with strict targets.
• Reduce packaging waste through minimisation and reuse schemes.
• Meet mandatory recycled content requirements for plastic packaging.
• Comply with extended producer responsibility (EPR) obligations.
• Ensure all packaging is appropriately labelled and documented.

As enforcement begins, businesses must proactively assess their packaging portfolios, work towards recyclability goals, and prepare for future regulatory deadlines to maintain market access and compliance.

For personalised support in meeting PPWR requirements, reach out to our compliance experts.